Zenvia is committed to preserving User privacy and protecting Personal Data collected of Users through our websites, as well as the products and services offered by Zenvia, in accordance with the laws in force applicable to our activities – especially the LGPD –, and act with transparency and clarity for Users and the market in general.
We strongly recommend reading this Policy carefully. When accessing and using the website’s features and Zenvia’s products and services, the User declares to be aware of this Policy and to be aware about the information presented here.
We, at Zenvia Group (“Zenvia Group” or “us”), are committed to safeguarding the privacy and protecting the personal data of our Customers, End Users of our products and services and visitors to our websites (“you”) . Therefore, we created this External Privacy and Data Protection Policy (“Policy”) to explain how we treat your personal data, with the aim of providing due transparency about the processing covered under this Policy.
This Policy applies to all Zenvia Group companies. If, after reading this Policy, you still have questions, feel free to contact us through the following channel [email protected].
To better understand the terms used in this Policy, we present the following definitions for your interpretation:
|Data Protection Authority||It is the public administration body responsible for ensuring, implementing and monitoring compliance with applicable privacy and data protection legislation.|
|Legal bases||These are the hypotheses provided for by law that authorize the processing of personal data.|
|Client||Those who contract a service provided by the Zenvia Group, including natural persons who, representing the contractor, operate the services.|
|Consent||Manifestation, under the terms of the law, by which the holder agrees to the processing of their personal data for a specific purpose. It is one of the hypotheses that authorize the processing of personal data.|
|Controller||Who is responsible for decisions regarding the Processing of Personal Data, especially regarding the purposes and means of Processing Personal Data.|
|Cookies||Small text files sent by the Zenvia Group’s technological infrastructure to the Holders’ device, with the purpose of identifying the device and obtaining access data, such as pages browsed or links accessed, thus allowing personalization of navigation on the website, in accordance with with your profile.|
|Personal data||Information related, directly or indirectly, to the identified or identifiable natural person.|
|Person in Charge/DPO (Data Protection Officer)||Individual or legal entity appointed by the Zenvia Group to act as a communication channel between the Zenvia Group, data subjects and the Data Protection Authority of each country in which the Zenvia Group has companies.|
|Zenvia Group||These are all companies that are in the same Economic Group as Zenvia, that is, the companies listed in “Annex I – Affiliate List” of this Policy.|
|Local Legislation||ZENVIA is a group with multinational operations. When we mention local laws in this Policy, we refer to the privacy and data protection laws applicable to our companies located outside Brazil.|
|Operator||The party that processes Personal Data in accordance with the Controller’s instructions.|
|Holder||Natural person to whom the personal data that is subject to processing refers.|
|Treatment||Any operation carried out with personal data, such as collection, storage, access, use, sharing, enrichment and elimination.|
|End Users||Natural persons, generally clients of the Clients, who access or interact with the products and services offered by the Zenvia Group.|
|Web Beacons||Small devices that use Bluetooth Low Energy (BLE) technology, which emit signals that can be captured by technological resources, enabling interaction between the user and the technological resource. Web beacons are programs designed to monitor a user’s navigation on a website.|
The types of personal data and how it is collected depend on how you interact with us and why. For example, if you only contact us through the “Talk to a consultant” channel available on our website, the data requested will not be the same as that collected if the company you work for hires one of our products.
To find out what data is collected and the respective purposes of collection in each case, see the table below.
03.1 Main treatment activities
|Purpose of Treatment||Processed Data|
|Access Log: We have a legal duty to store some of your information (such as your IP, date and time of access) to eventually provide it to legal authorities.||Navigation data: data collected through cookies or device IDs, including IP, date and time of access, geographic location, browser type, duration of visit and pages visited.|
|Registration on the Zenvia Group websites: Registration is necessary to test the platform for free or to access Zenvia Group’s e-commerce, services and products.||Name, username, position, email, password and company details.|
|Contracting services and products from the Zenvia Group.||Name, CPF, address, position, company details, telephone, email and bank details.|
|Answering questions, responding to requests and providing support regarding the use of ZENVIA products and services.||Name, email, telephone, company, recording (if contact is made by telephone).|
|Sending communications about offers, new opportunities, benefits, products, services and features.||Name, email, telephone and company.|
|Improving the functioning of the website, products and services.||Navigation, location and behavioral data on the Zenvia Group website and platforms.|
|Preparation of Customer satisfaction studies, management of the Customer base and creation of business intelligence indicators. Whenever possible, personal data will be anonymized.||Name, company, position, location data and responses to surveys carried out by the Zenvia Group.|
|Contact with suppliers, service providers, among others, for negotiation, analysis and budgeting of registration and billing information.||Name, CPF, address, position, company details, telephone, email and bank details.|
|Sending communications about vacancy opportunities made available in ongoing selection processes.||Name, email and telephone number provided in registrations on the Recruitment and Selection Platform used by the Zenvia Group.|
|Marketing actions aimed at communicating news from the Zenvia Group.||First and last name, email and telephone.|
03.2 Personal data of End Users
The Zenvia Group offers its Customers a communication platform so that they can communicate more efficiently with their End Users, through different channels.
Therefore, if you are an End User of one of the Zenvia Group’s customers, personal data collected by our customers and shared with us may be processed so that we can offer our services to our customers and, therefore, enable communication between you.
These technologies translate into small text files stored on your browser or device and help us understand your behavior and preferences, telling us which parts of our website you have visited and measuring the effectiveness of advertisements and web searches, e.g. .
Some cookies are automatically deleted when you close your browser (so-called session cookies), while others may be stored for longer on your computer until they are deleted manually or automatically (so-called persistent cookies). The Zenvia Group uses the following types of cookies:
The use of non-strictly necessary cookies is based on the Owner’s consent. Therefore, you can choose to allow the collection of some or all cookies. For more information about the cookies collected or to change your preferences for collecting cookies, you can select the “Cookie Declaration” menu in the banner at the page footer. We inform you that blocking some types of cookies may affect your experience on the website and the services that the Zenvia Group offers.
Please be aware that cookies used by third parties may continue to monitor your online activities even after you have left our website, and we recommend that you clear your browsing data regularly.
04.1 Web Beacons
Web beacons help Zenvia Group improve its understanding of web traffic and visitor behavior, as well as measure response to our promotional efforts. This information is used to obtain an overview of how visitors use our website.
In certain cases, we need and/or may share your personal data with third parties to, for example, support our business. Below we describe some situations in which your personal data may be shared:
To fulfill the purposes mentioned in items 3 and 5 of this Policy, depending on where you reside, we may share certain personal data with servers, suppliers and/or other Zenvia Group companies located abroad, in countries such as Argentina, Mexico, the United States and Brazil.
The Zenvia Group seeks to meet all requirements established by current legislation and adopts the best security and privacy practices to guarantee the integrity and confidentiality of your personal data throughout the entire procedure. Furthermore, it seeks to establish its contractual relationships guaranteeing conditions of data protection and information security obligations appropriate to the nature of the processing of personal data that we carry out and compatible with the requirements of legislation.
You are aware and agree, in advance, to the international transfer of your personal data to these countries when Local Legislation so requires. If you wish, you can oppose this type of transfer through the procedure described in item 12 of this Policy, but, in some of these cases, as a result of your opposition, unfortunately we will not be able to continue providing our services and offering new products to you.
From time to time, Zenvia Group may use your contact details, such as your email address, to send you marketing communications to promote our products and services in line with your interests. Whenever necessary, we seek to clearly identify our advertising content as such and obtain your consent, through this Policy or other appropriate means, when Local Law requires it. We provide, in all of our communications, an option for you to unsubscribe from receiving these messages if you prefer not to receive them again.
The Zenvia Group is responsible for taking care of your personal data and using it for lawful purposes, as described in this Policy. The Zenvia Group maintains an information security program designed to protect your personal data, seeking to ensure the confidentiality, integrity and availability of such information.
We adopt a series of appropriate technical, administrative and physical procedures, based on the highest standards of information security in order to protect your personal data from unauthorized access and accidental or illicit situations of destruction, loss, alteration, communication or dissemination . The data you provide to us is stored on secure servers and our contracts with suppliers and service providers generally have personal data protection clauses.
Events of unauthorized third-party entry or use of your account, hardware or software failure and other factors can compromise the security of your personal data and are increasingly common today. Therefore, your actions are also essential for maintaining a safe environment. You must also adopt good security practices in relation to your data (such as not sharing passwords with third parties). If you identify or become aware of something that compromises the security of your data, please contact us through the channel provided in item 12 of this Policy.
The Zenvia Group will store your personal data for the period necessary to fulfill the purposes for which it was collected. Even after the purpose of processing has been achieved or when data deletion is requested by you, some of your data may be kept in databases for the purpose of complying with legal or regulatory obligations, to protect the rights of the Zenvia Group, to satisfy the purposes described in this Policy, among other hypotheses with the appropriate legal basis.
Whenever possible, we will consider your right to request the deletion or opposition to the processing of personal data, as described in item 11 of this Policy and, if you request the deletion of your personal data, you will lose access to the services or benefits provided for the purposes for which they are treated.
As a rule, Zenvia Group websites, products and services are not targeted at and should not be used by children or adolescents. If the Zenvia Group identifies the processing of personal data of children and adolescents, the Zenvia Group will adopt the necessary measures to delete such data.
There are situations, however, in which the Zenvia Group performs the role of personal data operator, acting in accordance with guidelines passed on by its Clients. In these cases, you must contact the Zenvia Group Customer to exercise your rights.
The legislation guarantees you, the Personal Data Holder, a series of rights related to the processing of your data. We are committed to fulfilling these rights and, in this section, we will explain how you can exercise them with the Zenvia Group.
The legislation guarantees you the following rights:
|Confirmation and Access||It allows any holder to check whether the Zenvia Group processes their personal data and, if so, request a copy of the personal data we have about you.|
|Correction||Allows you to request the correction of your incomplete, inaccurate or outdated personal data.|
|Anonymization, blocking or deletion||It allows you to ask us to (a) anonymize your data so that it can no longer be linked to you and therefore no longer personal data; (b) block your data, temporarily suspending our ability to process it; and (c) delete your data, in which case we will delete all your personal data without the possibility of reversal, except in cases provided for by law.|
|Portability||You have the right to request, upon express request, that the Zenvia Group provides you, or a third party you choose, with your personal data in a structured and interoperable format, for transfer to another service or product provider, as long as it does not violate the company’s intellectual property or trade secret.|
|Sharing information||You have the right to know which public and private entities the Zenvia Group uses shared data with. In this Policy, we will keep the list of types of partners with which we share data up to date. In any case, if you have questions or want more details, you have the right to ask us for this information.|
|Information about the possibility of not consenting||You have the right to have clear and complete information about the possibility and consequences of not providing consent. Your consent, when necessary, must be free and informed. Therefore, whenever we ask for your consent, you are free to deny it – although, in these cases, we may have to limit our services.|
|Revocation of consent||You have the right to withdraw your consent in relation to the processing activities based on it. However, this will not affect the legality of any previously carried out processing. Furthermore, if you withdraw your consent, we may not be able to provide you with certain products and services.|
|Opposition||The law authorizes the processing of personal data even without your consent. If you do not agree with this treatment, in some cases, you can object to it, requesting interruption.|
|Review of automated decisions||You can request a review of decisions made based on automated treatments carried out by us, when applicable, as long as it respects the Zenvia Group’s business secrecy.|
To exercise any of the rights mentioned above, please complete the Data Subject Request Form, which is the preferred channel of communication with our Data Protection Officer (DPO) for this matter. In cases where the form is unavailable, you can send an email to the contact provided in item 12 of this Policy. For your security, whenever you submit a request to exercise your rights, Zenvia Group may request additional information to verify your identity, in order to prevent fraud and data processing contrary to this Policy. We do this to ensure the security and privacy of everyone, aiming to prevent the disclosure of personal data to unauthorized individuals.
In some cases, Zenvia Group may have legitimate reasons not to fulfill a request to exercise rights. These situations include, for example, cases in which disclosing specific information could violate Zenvia Group’s or third parties’ trade secrets, as well as cases in which requests for anonymization, blocking, or deletion of data cannot be fulfilled due to Zenvia Group’s obligation to retain data, either to comply with legal or regulatory obligations or to enable the defense of Zenvia Group’s or third parties’ rights, including in disputes of any nature.
In other cases, Zenvia Group may not be the Data Controller of personal data, as this role may be exercised by a Customer of Zenvia Group.
Finally, some requests may not be answered immediately, but Zenvia Group commits to respond to all requests within a reasonable timeframe and in accordance with applicable law.
If you have any questions, comments, or suggestions related to this Policy, please contact us. We have a Data Protection Officer (DPO) available at the following contact:
Data Protection Officer (DPO): Baptista Luz Advogados
Email: [email protected]
The Zenvia Group may update this Policy periodically to reflect changes in its business. Therefore, we recommend that you periodically visit this page so that you are aware of the changes made. If relevant changes are made, Zenvia Group will publish a notice on its website. The use of Zenvia Group’s services and products and its website after changes to the Policy means that you are aware of the changes made.
Updated on: November 8, 2023.
|MKMB Soluções Tecnológicas Ltda.||Avenida Paulista, n. 2300, conjuntos 182 e 184, São Paulo/SP, Brasil|
|Movidesk S.A.||Via Expressa Paul Fritz Keuhnrich, n. 1515, Itoupava Norte, CEP 89052-381, Blumenau/SC|
|One To One Engine Desenvolvimento e Licenciamento de Sistemas de Informática S.A.||Rua Luis Correia de Melo, 92, Conj. 281 e 282, Edifício Urbanity Corporate, Santo Amaro|
|Zenvia Mobile Serviços Digitais S.A.||Avenida Paulista, n. 2300, conjuntos 182 e 184, São Paulo/SP, Brasil|
|Zenvia Voice Ltda.||Avenida Paulista, n. 2300, conjuntos 182 e 184, São Paulo/SP, Brasil|
|Zenvia Inc.||PO Box 309, Ugland House, Grand Cayman, KY1-1104, Cayman Islands|
|Zenvia Mexico Sociedad de Responsabilidad Limitada de C.V.||Wisconsin No. 13, Col. Nápoles, Del. Benito Juárez – C.P. 03810|
|Rodati Motors Central de Informações de Veículos Ltda.||Avenida Paulista, n. 2300, conjuntos 182 e 184, São Paulo/SP, Brasil|
|Rodati Motors Corporation (E.U.A.)||3500 South Dupont Highway, Dover, County of Kent, DE 19901|
|Rodati Servicios S.A. de C.V. (MEX)||Av. Tamaulipas 150 – 1301B Condesa Cuatémoc, Ciudad de México, 06140. Buzón 96.|
|Rodati Services S.A. (ARG)||Cecilia Grierson 255, Piso 6°, Ciudad Autónoma de Buenos Aires. C1107CPE|
|Sensedata Tecnologia Ltda.(MEX)||Av. Tamaulipas 150 – 1301B Condesa Cuatémoc, Ciudad de México, 06140. Buzón 96.|
|Total Voice Comunicações S.A.||Rua da Praça, no 241, Bairro Pedra Branca, CEP 88137-086 – Palhoça – SC|